Monday, November 09, 2009

Title IID Entitlement Applications - HELP!!!

The applications are beginning to come in from districts for their share of the Title IID ARRA entitlement funds. I have had to ask for changes in several of those that I have received, because they were not done correctly or were incomplete. I am hoping that you can help me correct any confusion about how to complete this application, whether you are a person in district assisting in the writing of your own application or a regional consultant helping several districts with theirs.

There are two major issues:

The first deals with not completing all required sections, in particular both columns of page 5 that ask for the applicant to describe the planned use of funds and the accountability measures (how you will evaluate your use of funds in meeting Title IID program goals). Both of these sections must be completed for an application to be reviewed.

The second issue relates to the equitable services provision for private schools. Only ONE budget should be submitted with an application, and this should be for the total amount for which the district is eligible, including private school amounts. The detailed budget should note the private school expenses, but you do not need to submit separate budgets for private schools under Title IID, as the LEA is responsible for all expenditures. As stated in the USDoE guidance document for Equitable Services, “Under section 9501(d) of ESEA, the LEA must always maintain control of the program funds as well as title to all materials, equipment and property purchased with federal funds… only the LEA may obligate and expend federal funds on behalf of private school students and teachers. Thus, the LEA must purchase materials or procure services on behalf of the private school students and teachers. However, the LEA may use federal funds to reimburse an individual private school teacher, administrator, or other educational personnel for professional development that the LEA has pre-approved and that meets the reasonable and necessary cost principles of the Office of Management and Budget (OMB) Circular A-87.”